IEA Current Controversies No.

76

A SAFER BET
Gambling and the risks
of over-regulation
Christopher Snowdon
March 2021

Institute of
Economic Affairs
IEA Current Controversies papers are designed to promote discussion of
economic issues and the role of markets in solving economic and social
problems. As with all IEA publications, the views expressed are those of
the author and not those of the Institute (which has no corporate view),
its managing trustees, Academic Advisory Council or other senior staff.
 3

Contents

About the author 4

Summary 6
Introduction 9
The facts 10
The anti-gambling coalition 17
Towards better regulation 21
The risks of excessive regulation 30
Conclusion 32
References 34

44

About the author

 55

Christopher Snowdon is the Head of Lifestyle Economics at the Institute

of Economic Affairs. He is a regular contributor to the Spectator, Telegraph
and Spiked and often appears on TV and radio discussing lifestyle
regulation, prohibition and policy-based evidence. He is the editor of the
Nanny State Index and the author of five books: Killjoys (2017), Selfishness,
Greed and Capitalism (2015), The Art of Suppression (2011), The Spirit
Level Delusion (2010) and Velvet Glove, Iron Fist (2009). He has also
written more than twenty papers for the Institute of Economic Affairs
including ‘Drinking, Fast and Slow’, ‘Joint Venture’, ‘Cheap as Chips’,
‘Sock Puppets’ and ‘Death and Taxes’.
6

Summary

● T
 he government has launched a review into British gambling law ‘to
make sure it is fit for the digital age’. A coalition of activists has proposed
a range of anti-gambling measures, including an advertising ban, low
stake limits, a monthly spending cap, slower gameplay and a ban on
VIP schemes, bonuses and inducements.
● D
 espite the perception of a gambling ‘epidemic’ in Britain, the
number of people who gamble has not risen in the last decade
and there has been no rise in the rate of problem gambling since
records began in 1999. The number of children who gamble has
halved since 2011. In real terms, the amount spent on gambling
has declined since 2015.
● M
 any of the policies proposed by the anti-gambling coalition would
be incompatible with the government’s stated aim of respecting ‘the
enjoyment people get from gambling’ and ‘the freedom of adults to
choose how they spend their money’.
● A
 n advertising ban would make it more difficult for customers to
distinguish between the regulated and unregulated sectors. It would
deprive advertising platforms of an important source of revenue and
stifle competition. There is very little evidence that it would have any
impact on problem gambling.
● A
 ban on sponsorship would similarly hinder licensed operators from
establishing their brands. It could have a devastating impact on many
sports, such as lower league football, darts and snooker. There is no
evidence that it would yield any benefits.
 £2 stake limit for online games would have a similar effect as the
● A
£2 stake limit on fixed odds betting terminals, which is to say it would
make them unplayable for many gamblers. This is not regulation in the
 7

normal sense, but a form of neo-prohibition which would likely drive

players to unlicensed, unregulated and untaxed websites.
● A
 rtificially long gaps between online bets would be boring and frustrating
for players. As with the £2 stake limit, this policy can be seen as an
attempt to deter gambling per se rather than tackle problem gambling.
The technology exists to track harmful patterns of play and intervene.
Sophisticated algorithms and timely interventions for the minority of
high-risk gamblers are more effective than simplistic, blunt tools.
● L
 imiting the amount people can spend on gambling each month would
be extraordinarily paternalistic. There is no other market in which
consumers are restrained by the state from spending more than a
certain amount of money. Although it has been suggested that the
deposit limit could be lifted for those who can prove that they can
afford it, it is not easy to see how this could be done without significant
bureaucracy and the invasion of privacy. Ordinary people who want to
gamble with their own money would be treated as if they were taking
out a mortgage or living off the proceeds of crime.
● P
 rotecting the vulnerable and preventing gambling becoming a source
of crime are two of the three key objectives of British gambling law.
The policies proposed by anti-gambling campaigners could undermine
both of these by stimulating demand for unregulated websites that can
be easily found via internet forums, search engines and affiliate sites.
Many players will be unwilling to tolerate online content that has been
made deliberately tedious and unexciting by limits on speed of play
and stakes/prizes. Unregulated online casinos closely resemble their
regulated competitors and, if advertising is also banned, consumers
could have great difficulty distinguishing one from another.
● U
 se of unlicensed gambling websites is relatively rare in Britain, but it
is not unknown. Unregulated websites are used by 4.5 per cent of UK
online gamblers and 44 per cent are aware of at least one unlicensed
site. Research from Sweden suggests that players of online casino
games, slots, poker etc. are particularly willing to use unregulated
websites. These are the consumers who would be most affected by
the kind of policies currently being proposed in the UK.
● A
 better answer lies in technology. The ability of ‘Big Data’ to identify
problem gamblers and prevent harm is unlike anything we have seen
before. Regulated online operators use a range of practical harm
reduction measures which advance the government’s objectives without
infringing the rights of the average punter or handing a competitive
8

advantage to the unregulated sector. Not every company uses their

technology to prevent harm in the same way, but best practice could
be made standard through regulation. It is these practical solutions,
not the blunt tools of anti-gambling activists, that could be the focus
of the government’s review.
 9

Introduction

Fourteen years after the reform of Britain’s gambling laws, the issue
remains controversial. Despite a string of new regulations and the near-
eradication of fixed-odds betting terminals in bookmakers, a coalition of
anti-gambling activists is pressing for a further clampdown. After promising
to review the Gambling Act ‘to make sure it is fit for the digital age’, the
government launched a public consultation in December 2020 ‘to assess
whether we have the balance of regulation right’ (DCMS 2020a). Activists
are hopeful that it will lead to primary legislation with severe restrictions
on stake limits, advertising, promotion and perhaps even a limit on how
much players can spend.

Although the media narrative about gambling is largely driven by those

who want to restrict consumer choice, the government acknowledges that
gambling is a ‘fun leisure activity for many people’ (ibid.) and it ‘recognises
the need to balance the enjoyment people get from gambling with the right
regulatory framework and protections’ (DCMS 2020b). Britain’s gambling
industry is worth £14.3 billion a year, pays £3 billion in tax and employs
100,000 people. This paper examines the gambling market, assesses the
likely impact of the measures proposed, and looks at constructive policies
that could serve the interests of consumers.
 10

The facts

Table 1

Repeated claims in the media about Britain being in the grip of a gambling
‘epidemic’ with a growing number of ‘addicts’ are not supported by the
evidence. Since these claims are widely believed, we begin by establishing
the facts.

Gambling participation
The number of gamblers in Britain has fallen somewhat in recent years,
mostly because of the declining popularity of the National Lottery. Figure
1 shows adult gambling prevalence (past month), with the dotted line
showing2011 the proportion of Britons who engage in non-Lottery gambling.
The latter2012has remained57
54.8
steady at around a third of the population. Gambling
2013 28
participation
2014 fell in 2020,
55.5 largely
35 as a result of Covid-19. Looking at the

more typical
2015 year of46.6
2019, the most28 common gambling activities were the
47.2
National Lottery (2945.5per cent), other lotteries (12 per cent), scratchcards
2016 31.4

2017 32.1
(11 per cent),
2018
sports45.8betting (731.5
per cent), private betting (5 per cent), slot
machines 2019(4 per cent)46.7
and horse
32.4 racing (4 per cent).

2020 42.7 29.2

Figure 1: Adult gambling prevalence in the past month

100
Past month gambling prevalence (%) UK adults

80

60
All gambling

40

Excluding National Lottery games

20

0
2012 2013 2014 2015 2016 2017 2018 2019 2020
 11

Gambling2011among children
23 has fallen more sharply. Figure 2 shows past
week gambling
2012
activity
18
by 11-16 year olds (Gambling Commission 2020).
2013 15
In 2020,2014
nine per cent
16
reported gambling in the previous seven days. The
most common
2015 activities
17 were private bets with friends, playing cards for
money and playing a National Lottery game, all of which were reported
2016 16

2017 12
by three2018
per cent of 14
the sample. No other gambling activity was reported
by more2019
than two per11 cent of the sample.

2020 9

Figure 2: Gambling prevalence among children in the past week

25
Past week gambling prevalence (%) 11-16 year olds

20

15

10

0
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

It is possible that children under-report their gambling in surveys, especially

when the activity is illegal. On the other hand, when dealing with such
small percentages, it is worth remembering that school children may not
always take such surveys seriously. For example, two per cent of 11 year
olds in the Gambling Commission survey reported having gambled in a
casino in the past week, which seems very unlikely.
4

In any case, the overall number of children engaging in any form of gambling
is low and getting lower, and most of the activities are legal, non-commercial
and cannot be affected by regulation.

Problem gambling
Rates of problem gambling have been low ever since they were first
measured by the government in 1999. They have barely fluctuated in the
intervening years. The results from the two internationally recognised
surveys are shown in Figures 3 and 4.
 12

The Problem Gambling Severity Index (PGSI) has been used since 2007,
initially in the British Gambling Prevalence
Table 1 Survey and subsequently in
the Health Surveys for England, Scotland and Wales. A simplified version
1999 0.6
of the2000survey was0.6
introduced in 2013, featuring three questions about
respondents’
2001 activity
0.6 in the past 12 months:
2002 0.6

2003 0.6
1. Have
2004
you bet more
0.6
than you could really afford to lose?
2. Have
2005 people criticised
0.6 your betting or told you that you have a gambling
problem?
2006 0.6

2007 0.6
3. Have
2008
you felt 0.63
guilty about the way you gamble or what happens when
you gamble? 0.66
2009

2010 0.7

2011 0.65
The options
2012
are ‘never’,
0.6
‘sometimes’, ‘most of the time’ and ‘almost always’,
with scores
2013 of 0, 1,
0.5 2, 3 respectively. A score of four or more classifies the

person2014as a problem
0.5 gambler (although campaigners and journalists often
refer 2015
to ‘gambling0.5addicts’, this is not a scientific term and the surveys do
2016 0.7
not measure
2017 ‘addiction’).
0.5
1
There has been no statistically significant change
in problem
2018 gambling
0.5 prevalence by the PGSI measure over the years,
with rates
2019
hovering0.5
around 0.6 per cent of the population.
2020 0.6

Figure 3: Adult problem gambling prevalence (PGSI)

2
Problem gambling prevalence (PGSI)

1.5

PGSI mini-screen

survey begins
1

0.5

0
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

1  If a person scores more than zero, they are classified as an ‘at risk’ gambler. It is far from
clear that being ‘at risk’ has any clinical significance (Delfabbro and King 2017), but the
numbers are much larger, with 1.8 million people in the UK ‘at risk’ compared with 350,000
problem gamblers. With the number of problem 1 gamblers failing to rise, campaigners
have increasingly cited the number of ‘at risk’ gamblers.
 2002 0.6

2003 0.6

2004 0.6

2005 0.6

2006 0.6 13
2007 0.6

2008 0.7

2009 0.8

2010 0.9
Similarly,2011
the DSM-IV 0.7
survey method suggests that rates of problem
gambling2012
have been low 0.5 and essentially flat for twenty years. The British
Gambling2013Prevalence 0.56 Survey reported DSM-IV problem gambling
2014 0.64
prevalence2015
estimates0.7in 1999, 2007 and 2010. Since 2012, the data have
been collected
2016 in the0.6Health Surveys for England, Scotland and Wales,
which classify
2017 gambling
0.55 as a ‘health-related behaviour’. Figure 4 shows
2018
that mid-point prevalence0.5
estimates have ranged between 0.5 and 0.9
2019
per cent, 2020
with no upward trend since 1999.

Figure 4: Adult problem gambling prevalence (DSM-IV)

2
Problem gambling prevalence (DSM-IV)

1.5
Health Survey

data begins

0.5

0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Rates of problem gambling are very low among women (0.1-0.3 per cent).
Among men, it is much more common among the 25 to 34 age group than
any other. This has been the case for as long as the UK has been measuring
problem gambling. Rates are consistently less than half as high among
35 to 44 year olds, which suggests that problem gambling is usually a
temporary ‘condition’ that most people grow out of or otherwise overcome.
2

Problem gambling among children

Estimates of the rate of problem gambling among children did not exist
in Britain until 2014, when the Gambling Commission began collecting
the relevant data based on a different set of questions in a survey known
as the DSM-IV-MR-J. Unfortunately, several methodological changes have
made it impossible to discern a trend. There was no rise between 2014
and 2016 but, in 2017, the age of children interviewed rose from 11 to 15
year olds to 12 to 16 year olds. Then, in 2018, an online version of the
test was introduced. This produced a much higher prevalence estimate
than the pen-and-paper test: the former suggested that 2.1 per cent of
children were problem gamblers whereas the latter suggested a figure of
 14
2014 0.7

2015 0.6

2016 0.4

2017 0.9
0.6 per 2018
cent. Since 0.62019, the 2.1
test has only been conducted online and
the estimate
2019
has been 1.7 per 1.7cent (see Figure 5).
2020 1.9

Figure 5: Problem gambling prevalence among children

2.5
Problem gambling prevalence (DSM-IV-MR-J)

2 Online test
Age range increased

1.5

1 Test moves exclusively online

0.5
Pen-and-paper test

0
2014 2015 2016 2017 2018 2019 2020

There is no conclusive explanation for why the online test produces higher
estimates, but it seems likely that it picks up many false positives. If taken
at face value, the most recent figure suggests that 1.9 per cent of 11 to
16 year olds are problem gamblers. Among 16 year olds specifically, the
rate is reported to be 3.5 per cent. These figures seem implausible given
that the rate among 16 to 24 year olds is 3 only 0.8 per cent.

Regardless of which measure is more accurate, the apparent rise in recent

years is clearly the result of methodological change, although that did not
stop the BBC claiming that the ‘number of children classed as having a
gambling problem has quadrupled to more than 50,000 in just two years’,
thereby fuelling the sense that Britain was in the grip of a growing epidemic
(BBC 2018).

Given that the number of 11 to 16 year olds who gamble has fallen
significantly in recent years, as shown in Figure 2 above, it would be
surprising if problem gambling had truly risen among the same age group.
Although the claim that 55,000 children are problem gamblers is often
repeated, it should be treated with caution.
 15

International comparisons
It seems clear that the adult problem gambling rate has been around 0.6
per cent for the last 20 years, seemingly unaffected by new innovations
in the industry and changes in regulation. Is 0.6 per cent a big number?
Not when compared to other countries. An extensive study by Williams et
al. (2012: 5) used a consistent methodology to estimate problem gambling
rates in 26 countries and found that:

Depending on the specific country and the survey year, the

standardised past year rate of problem gambling ranges from 0.5%
to 7.6%, with the average rate across all countries being 2.3%. In
general, the lowest standardised prevalence rates of problem
gambling tend to occur in Europe, with intermediate rates in North
America and Australia, and the highest rates in Asia. More specifically,
the lowest standardised prevalence rates occur in Denmark, the
Netherlands, and Germany. Lower than average rates are seen in
Great Britain, South Korea, Iceland, Hungary, Norway, France, and
New Zealand. Average rates occur in Sweden, Switzerland, Canada,
Australia, United States, Estonia, Finland, and Italy. Above average
rates occur in Belgium and Northern Ireland. The highest rates are
observed in Singapore, Macau, Hong Kong, and South Africa.

Problem gambling among children in Britain is also ‘towards the lower end
of the range of rates of adolescent problem gambling seen across other
countries’, as the government acknowledges (DCMS 2020a). Indeed, even
the higher figure of 1.9 per cent reported in the internet surveys is comfortably
below the international average for children (Calado et al. 2017).

Gambling expenditure
In a 2020 report, the National Audit Office (2020: 7) claimed that ‘Gambling
in the UK has grown rapidly over the past decade seeing a 57% increase’.
This figure has been repeated by the All Party Parliamentary Group on
Gambling Related Harm and the BBC, but it is highly misleading. The
National Audit Office clarifies that the rise is ‘mostly due to a significant
increase in licensed online and mobile gambling, which did not need to
be licensed in Britain before November 2014 if it was based overseas’.
This is, in fact, the whole reason for the apparent increase. In real terms,
there has been no rise in gambling spend in the last five years (see Figure
6), and the totals before and after 2015/16 are not comparable.
 Apr 2010 - Mar 2011 3,671.62 219.92 3,823.03 808.71 1,030.86 506.75

Apr 2011 - Mar 2012 3,838.76 280.93 3,722.87 836.39 1,072.53 468.26

Apr 2012 - Mar 2013 3,905.01 325.08 3,808.67 834.59 1,144.78 427.13

Apr 2013 - Mar 2014 3,583.52 339.64 3,672.50 778.53 1,284.45 438.26

16
Apr 2014 - Mar 2015 3,648.90 394.84 3,688.19 766.59 1,309.35 387.22

Apr 2015 - Mar 2016 3,819.22 424.49 3,708.99 774.74 1,117.09 467.30

Apr 2016 - Mar 2017 3,270.54 485.79 3,635.35 751.35 1,277.58 466.58

Apr 2017 - Mar 2018 3,187.84 538.34 3,463.84 720.83 1,251.39 449.89

Apr 2018 - Mar 2019 3,159.36 555.90 3,346.20 690.81 1,086.35 447.27

Figure 6: Gross Gambling Yield by UK registered companies

Apr 2019 - Mar 2020 3,184.60 572.51 2,811.67 668.95 1,052.74 461.72

(adjusted for inflation)

National Lottery Other lotteries Betting Bingo Casinos Arcades Remote

Apr 2008 - Mar 2009

Apr 2009 - Mar 2010

Apr 2010 - Mar 2011

Apr 2011 - Mar 2012

Apr 2012 - Mar 2013

Apr 2013 - Mar 2014

Apr 2014 - Mar 2015

Apr 2015 - Mar 2016

Apr 2016 - Mar 2017

Apr 2017 - Mar 2018

Apr 2018 - Mar 2019

Apr 2019 - Mar 2020

- 4,000.00 8,000.00 12,000.00 16,000.00
Gross Gambling Yield (in 2020 £ millions)

In 2014, the Gambling (Licensing and Advertising) Act required all offshore
gambling companies trading with UK customers to be licensed by the
Gambling Commission, taxed by the British government and comply with
British gambling regulation. This led to a huge increase in recorded
gambling spend in the remote sector in 2015/16, but it only made previously
unrecorded expenditure visible. Prior to 2015/16, online gambling revenue
had been significantly underestimated.

For this reason, the period between 2008/09 and 2014/15 cannot be
compared with the period between 2015/16 to 2019/20. In practice, there
has been a shift to online spending, as in many industries, but the claim
that there has been 57 per cent growth8
overall is not supported by the
evidence.

Since 2008, there has been a decline in spending on the National Lottery,
bingo and arcades, and an increase in spending on other lotteries and remote
gambling. Casino revenue has remained fairly stable and betting shop
revenue was stable until 2017 when it began to decline. It is also interesting
to note that betting industry revenue did not increase in real terms after 2008
despite the widespread availability of fixed-odds betting terminals - termed
the ‘crack cocaine of gambling’ by their critics - in betting shops.
 17

The anti-gambling coalition

Aside from the creation of the National Lottery in 1993, the Gambling Act
(2005) was the first piece of major gambling legislation since 1968. Its
three priorities were to protect children and vulnerable people, prevent
gambling being a source of crime, and ensure that gambling was conducted
in a fair and open way. These remain the government’s chief objectives.

The Gambling Act represented a shift in attitude, with gambling treated

as a legitimate and normal leisure activity after decades of being grudgingly
tolerated. The Blair government found that gambling was still viewed as
immoral in some circles and the legislation was the subject of a considerable
media storm before being watered down shortly before the 2005 general
election. Various concessions were made to faith groups and the incumbent
gambling industry. No ‘super-casino’ was ever built and the casino industry
remains subject to arbitrary restrictions which inhibit its growth (Snowdon
2012). The 2005 Act’s main achievements were to legalise gambling
advertising, create the Gambling Commission as industry overseer and
regulate online gambling for the first time.

When concerns about gambling re-emerged in the following decade, they

were not focused on casinos, which had been the target of tabloid fears
in 2005, nor on online gambling, which was the most rapidly growing
sector, but on machines in betting shops. Fixed-odds betting terminals
(FOBTs) allowed players to stake up to £100 on digital casino games such
as roulette and blackjack. Derek Webb, a former professional poker player
and casino game inventor, set up two campaign groups - the Campaign
for Fairer Gambling and Stop the FOBTs - after finding three card poker,
which he had invented, on an FOBT in 2007. He considered legal action
but, as he told the Guardian in 2013, ‘rather than sue I backed a campaign
to make my point’ (Ramesh 2013). By 2017, he had spent £3 million of
his personal fortune on the campaign (Ahmed 2017a).
18

A coalition formed around the issue which included the Salvation Army,
several think tanks, problem gambling charities and various bishops, as
well as businesses in the rival arcade, casino and pub industries. The All
Party Parliamentary Group on FOBTs was formed and a number of
prominent politicians, including Tom Watson (deputy Labour leader 2015-
19) and Tracey Crouch (Sports Minister 2018-19), became vocal supporters
of a drastic cut in the FOBT stake limit - from £100 to £2 - which would
make FOBTs unattractive to most punters.

Campaigners referred to FOBTs as the ‘crack cocaine of gambling’ - a

term coined in the 1980s by Donald Trump when he was lobbying against
digital competition to his casinos - and the media soon adopted the phrase
(Snowdon 2013). The result was a widespread perception that gambling
expenditure, problem gambling and the number of betting shops were all
growing rapidly. None of this stood up against the facts, but the government
capitulated nonetheless, cutting the maximum stake on the machines to
£2 in April 2019.

This proved to be only the start. In the last two years, the government and
the Gambling Commission have introduced a range of new regulations
related to gambling. In April 2020, gambling with credit cards was banned
and all online gambling operators were required to join the national self-
exclusion system GAMSTOP, thereby preventing problem gamblers who
exclude themselves from gambling websites from playing on any regulated
site. In 2019, the government announced plans to set up fourteen NHS
problem gambling clinics by 2023/24. Teaching about the risks of online
gambling became mandatory in state schools in September 2020 under
the Health Education curriculum. The age at which the National Lottery
can be played will be raised from 16 to 18 in October 2021.

There has also been a growth in industry self-regulation, with all the big
operators signing up to codes of conduct on advertising and player protection.
In August 2019, most of the big gambling companies introduced a voluntary
‘whistle-to-whistle’ advertising ban, in which no gambling advertisements
can be shown during or shortly before and after live sport on television.
They also agreed to ensure that at least twenty per cent of their broadcast
advertising promotes safer gambling. When the first Covid-19 lockdown
began, the industry agreed to a six-week voluntary ban on all gambling
advertising. Since November 2020, people aged 25 or under are not eligible
to join VIP reward schemes, which offer perks to loyal customers, and
those who do are subject to ongoing checks on their gambling behaviour.
 19

None of this has appeased anti-gambling campaigners. Paying the

Danegeld never gets rid of the Dane. The victory against the supposed
‘crack cocaine of gambling’ has been all but forgotten and nobody is
claiming that the number of problem gamblers has fallen as a result. The
voluntary restrictions on advertising introduced during the first lockdown
were taken as ‘a clear acknowledgement by the industry of the harm that
advertising can cause’ by the industry’s critics (APPG on Gambling Related
Harm 2020: 20) and the ban on gambling with credit cards inspired
campaigners to call for a ban on gambling with loans and overdrafts (with
no explanation of how this could be enforced). Much of the rhetoric used
in the campaign against FOBTs has now been repurposed and redirected
at the online sector.

In an interview with the Financial Times in 2017, Derek Webb suggested

that he would start campaigning against online gambling once he had won
his battle against FOBTs (Ahmed 2017a). So it has proved. Webb now
funds Clean Up Gambling, a pressure group run by Matt Zarb-Cousin who
previously worked for the Campaign for Fairer Gambling. It wants a levy
on the gambling industry and a stake limit on all online games. It also
wants a total ban on gambling advertising. Clean Up Gambling co-ordinates
yet another group, the Coalition Against Gambling Ads, to campaign for
the latter.

‘Mission creep’ is a common feature of pressure politics. It often requires

new arguments to be made and old arguments to be forgotten. As Zarb-
Cousin (2019) explained in 2019, ‘The case for a £2 cap was built by
proving FOBTs were addictive, facilitated money laundering, put staff at
risk of abuse, and were subject to disproportionate levels of criminal
damage’. None of these issues are relevant to online gambling, except
the vexed question of ‘addiction’, which can apply to any form of gambling.
In a submission to government in 2013, the Campaign for Fairer Gambling
(2013: 34) stated that ‘FOBTs is [sic] the only gambling activity
significantly and positively associated with disordered gambling’
(emphasis in the original). Such claims have clearly outlived their usefulness,
but the activists are on a roll and the anti-gambling coalition has reassembled
to push for the new set of demands. The General Synod of the Church of
England (2019) has passed a motion to reduce the ‘quantity and
pervasiveness of gambling advertising’ which, it said, ‘has become a major
public concern, because it is seen to be everywhere’. In January 2019,
the APPG on FOBTs changed its name to the APPG on Gambling Related
Harm and gave itself a wider remit. The group, which received £30,000
 20

in registrable financial benefits from Webb in 2020,2 published a report

calling for a £2 stake limit on online slot games, a ban on all gambling
advertising, a levy on the gambling industry, a ban on in-play sports betting,
and ‘significantly slowing down the speed of “Random Number Generated”
digital slots and roulette’.

Like Clean Up Gambling, the APPG wants to ban all VIP schemes and
inducements, such as free bets. It has also called for mandatory ‘affordability
limits’ on the amount gamblers can spend. This policy has been endorsed
by the Social Market Foundation (SMF) in a report published in August
2020 that acknowledges Derek Webb as a financial supporter (Noyes and
Shepherd 2020). The SMF recommends a ‘soft cap’ limiting online deposits
to £100 a month. Under this system anyone who wants to spend more
than £23 a week on gambling would have to prove they could afford to
do so without experiencing hardship.

Finally, in June 2020, the House of Lords’ Select Committee on the Social
and Economic Impact of the Gambling Industry published a report calling
for heavier restrictions on gambling advertisements and inducements
(though not an outright ban), more stringent affordability checks, and the
speed of play on online games to be slowed down to the same level as
seen in casinos, betting shops and bingo halls.

2 Register
 of All-Party Parliamentary Groups (p. 569) (https://publications.parliament.uk/
pa/cm/cmallparty/201104/register-201104.pdf).
 21

Towards better regulation

The recent wave of anti-gambling advocacy comes in the wake of the

Conservative Party’s promise to ‘review the Gambling Act 2005 to make
sure it is fit for the digital age’. Oliver Dowden, the Secretary of State for
Digital, Culture, Media and Sport, has described the Act as ‘an analogue
law in a digital age’ (DCMS 2020b). This is an exaggeration. Most UK
households had access to the internet in 2005 and the Act regulated online
gambling. The main development in the years since has been the
widespread adoption of smartphones, but this does not seem sufficient
justification for the whole Act being repealed and replaced with new primary
legislation, as some anti-gambling campaigners hope. Most of their
demands, such as advertising restrictions and stake limits, are not specific
to smartphones, or even to online gambling.

In the discussion about gambling reform, free-market and liberal voices

are rarely heard. In this section, we will look at the proposals from the
activists, many of which are essentially paternalistic, and see how they
could affect the consumer.

Advertising and sponsorship

Gambling advertising in Britain is subject to extensive regulation and self-
regulation. The Advertising Standards Authority (2020) has strict rules on
content and has banned adverts in the past for encouraging gambling
after a loss, implying that gambling could solve financial problems, appealing
to children, and much more besides. Adverts cannot feature anyone who
is, or appears to be, under the age of 25. They cannot encourage people
to ‘Bet Now!’ or encourage repetitive play. Online advertisements on
platforms such as YouTube have to be age-gated. These rules were made
more stringent in 2018.
22

The Industry Code for Socially Responsible Advertising requires operators

to include responsible gambling messages in advertisements and forbids
adverts being shown on television before 9pm except for bingo, lotteries
and sports betting around televised sport (Industry Group for Responsible
Gambling 2020). In August 2019, the major operators introduced a voluntary
‘whistle to whistle’ advertising ban in which gambling adverts are not shown
from five minutes before the start of a sports broadcast to five minutes
after the end (horse-racing is exempt).

Moral reformers often take aim at advertising, but according to Harris and
Seldon (2014: 39) in Advertising in a Free Society, we should not yield to
‘critics who aim at the reflected image instead of declaring openly against
smoking or gambling or hire purchase or whatever it is they dislike. While
the law permits such activities, their advertising must be tolerated’. Pressure
to ban gambling advertising comes principally from activists who seem to
be simply opposed to gambling and anything that promotes it. For them,
a ban on gambling advertising would be symbolic. It would signal that
gambling is socially undesirable and that more should be done to stamp
it out.

If this is the motive, it does not warrant government coercion. In the 2001
report that paved the way for the 2005 Gambling Act, the economist Alan
Budd commented: ‘if the underlying activity is properly regulated, there
should be no objection in principle to the product being advertised’ (Budd
et al. 2001: 124). Interestingly, Budd expected the promotion of gambling
to lead to a rise in problem gambling. As we have seen, that did not happen;
the Advertising Standards Authority (2018: 3) makes the obvious point
that ‘problem gambling rates have remained stable during a period of quite
considerable growth in advertising volumes’. The growth in gambling
advertising in recent years has not led to more people gambling, nor has
it led to more money being spent on gambling. Although children’s exposure
to advertising is often cited as a justification for a ban, the number of
children who gamble has fallen in the last decade.

The ‘harm’ associated with gambling is of a fundamentally different kind

to that associated with unhealthy products. Whereas cigarettes are
inherently harmful to health, the harm from gambling comes from a small
minority of consumers spending more than they can afford. The ‘harm’
from gambling advertising is more tenuous still. Having looked at the
evidence, the Advertising Standards Authority concluded that ‘data on
problem gambling suggests gambling advertising has, at most, a very
 23

limited causal role and is unlikely to have contributed to an increase in

harm’ (ibid.: 7). Upon launching the recent public consultation, the
government cited no evidence of harm, but instead mentioned ‘growing
public concern about the relationship between sport and gambling’ as a
possible justification for additional regulation (DCMS 2020a).

A ban on gambling advertising may indeed be popular with much of the

public. Advertising, in general, is not particularly popular with the public,
who tend to disassociate it from the many free or subsidised services it
pays for. Gambling advertising spend has risen in recent years as new
operators sought to establish themselves and incumbent businesses
fought to protect their market share. Restrictions on when adverts can be
shown have led to a high volume of advertising on certain channels at
certain times (mostly after 9pm). Some viewers find the sheer number of
adverts for a service they do not use irritating. But that may not be a good
justification for government coercion. It is broadcasters who decide which
advertisements to broadcast, not viewers.3

Tiresome as advertising can sometimes be, it benefits consumers in two

important ways. Firstly, it stimulates competition and allows new entrants
to make themselves known, thereby lowering prices and encouraging
innovation. Secondly, it allows brands to establish themselves. Building
a brand can be an expensive process, but that, in itself, acts as the
consumer’s guarantee. Businesses which cannot afford their brands to
be tarnished have a strong incentive to maintain standards.

This is particularly important in the online gambling sector. A huge range

of gambling websites are available worldwide, not all of them reputable.
Only those registered with the Gambling Commission can advertise in
Britain. As the government acknowledges, the freedom to advertise is
‘one of the primary advantages that licensed and regulated operators have
over the black market’ (HM Government 2020). This, combined with the
costs required to advertise on television, means that consumers can be
confident they are not dealing with a fly-by-night operation, but with a
regulated, registered, taxpaying business.

3 In reality, gambling advertising amounted to £234 million in 2018 which is 4.6 per cent
of the total spent on TV advertising (£5.1 billion). Television advertising accounts for only
15 per cent of gambling advertising spend.
24

Sponsorship
Sponsorship is almost entirely about branding and seldom involves a ‘call
to action’. The House of Lords report does not support a full advertising
ban, but it does call for a ban on gambling companies sponsoring sports
teams. Again, it is the sheer volume of sports sponsorship, rather than
the principle, that seems to bother people. Eight of the twenty Premier
League teams are currently sponsored by gambling companies. In the
Championship, which is itself sponsored by SkyBet, twelve of the 24 teams
have gambling sponsors on their shirts (but not on children’s merchandise,
including replica kits).

The high volume of sponsorship reflects the highly competitive nature

of the market. Online gambling is still a relatively new industry and has
yet to be consolidated. For companies predominantly involved in sports
betting, there is an obvious synergy with sports teams and sporting
events. The amount of gambling sponsorship in football will probably
decline as the market matures, but the quantity should not be the issue.
Either gambling sponsorship is so harmful as to warrant prohibition or
it is not. Proponents of a ban have found almost no evidence to support
them. The House of Lords committee (2020: 132), which opposes a full
advertising ban because there is insufficient evidence, says a ban on
sports sponsorship ‘would in our view be very beneficial’, but it does not
say why.

Gambling companies would not be the biggest losers from a ban on

advertising and sponsorship. It would be broadcasters, advertising
platforms and football clubs who would suffer, along with smaller gambling
companies who would face a barrier to entry. Indeed, the big gambling
companies could benefit, as Professor David Forrest told the House of
Lords committee (ibid.: 129):

It is striking that in jurisdictions which have moved against sponsorship

and advertising by the betting sector—Australia and Italy—opposition
from the betting industry has been muted but that from sports leagues
and broadcasters strong. This may reveal that betting houses
themselves perceive their marketing as about brand share rather
than extending the market and there would be some advantage to
them from the state doing what competition law prevents them from
 25

doing for themselves—negotiating away heavy marketing budgets

which just cancel each other out.4

Breon Corcoran, who led the merger between Paddy Power and Betfair,
appears to agree, saying in 2017: ‘The thesis that, as barriers for entry
go up the small guys will suffer, is increasingly evident’ (Ahmed 2017b).

Top tier football teams will never struggle to find sponsors, but excluding
a whole industry would create a ripple effect and reduce revenues from
top to bottom. There is no reason to expect other industries to increase
their marketing spend to make up the shortfall. Clubs will have to lower
their asking price to attract new sponsors, and sports which rely heavily
on gambling sponsorship, such as darts and snooker, will be hit hard. The
House of Lords committee (2020: 132) acknowledges that a sponsorship
ban would ‘not unduly harm Premier League clubs, but it would very probably
have a serious effect on smaller clubs; some of those in the EFL might go
out of business without this sponsorship if they cannot find alternatives’.

This is a high price to pay for a policy with no proven benefits. Gambling
advertising and sponsorship have not led to any measurable harm since
they were legalised in 2007 and there is no reason to think their prohibition
would reduce harm. Marketing of gambling products is subject to stringent
regulation, and the maintenance of strong brands helps consumers
distinguish between regulated and unregulated companies. There will
always be people who would prefer not be reminded of legal activities of
which they disapprove, but that does not justify censorship.

Stake limits
The idea of capping online stake limits to £2, as proposed by the APPG
on Gambling Related Harm, is taken directly from the anti-FOBT playbook.
To people unfamiliar with gambling products, it may seem anomalous that
traditional slot machines have stake limits of one or two pounds while
FOBTs had a stake limit of £100. But FOBTs were not jackpot machines.
Players typically stood to win whatever they staked. When roulette and
blackjack are played in casinos, the minimum stake is typically £5 or £10.
For many players, anything less than £5 provides too little risk and reward
to make it interesting.

4 The House of Lords committee concluded: ‘We suspect that Professor Forrest may be
right in thinking that operators are happy to cease advertising if they can be sure that
other operators will do the same’ (ibid.: 130).
 26

Cutting online stakes to £2 should therefore not be seen as a minor regulatory

change, but as a way of deterring play altogether. Anti-FOBT campaigners
were keenly aware that it virtually amounted to de facto prohibition. Not for
nothing was Derek Webb’s pressure group called Stop the FOBTs. The explicit
aim was to get the machines out of bookmakers altogether - and they
succeeded. The number of FOBTs in betting shops plummeted from 32,661
to 1,003 after the new stake limit was introduced.5 The government would
therefore only introduce a £2 stake online if it is trying to get rid of these games
too. It would not be regulation in the normal sense, but a form of neo-prohibition.6

In practice, the government cannot stop people playing for higher stakes
because unregulated gambling websites are within easy reach of anyone
with an internet connection. This is not to say that there should be no
stake limit whatsoever, but it should be several standard deviations from
the mean. It could be set high enough for virtually all players to get a
sufficient sense of risk and reward.

Speed of play
The House of Lords committee (2020: 53) recommends ‘the equalisation
of speed of play and spin, so that no game can be played quicker online
than in a casino, betting shop or bingo hall’. This assumes that the speed
at which the games are played in traditional settings is optimal. It is a sort
of naturalistic fallacy. Flawed in principle, it is also wrong in practice since
‘traditional’ games are not necessarily slow. Slot machines are played at
a rapid pace, with a spin every two seconds being typical, and a one-on-
one game of blackjack in a casino can be played surprisingly quickly.

Artificially creating long gaps between online bets would be boring and
frustrating for the player, but for anti-gambling campaigners that would be
a feature rather than a bug. As with the £2 stake limit, the aim is not so
much to reduce ‘harm’ as to deter people from playing altogether. There
may be a case for mandatory breaks or ‘cooling off’ periods in online
gambling after a certain amount of time, or after a certain amount of money
has been spent. The technology exists to do this and operators have been
providing these kinds of harm reduction features for years.

5 They
 were largely replaced by B3 jackpot machines which players can stake £2 on every
2.5 seconds. Their numbers rose from 114 to 28,655 in the same period.
6 Noyes and Shepherd (2020: 34) note that a £2 stake limit on non-slot games, such as
roulette, would ‘lead to a revenue loss of 92% - essentially making that content no longer
commercially viable’.
 27

There is a telling inconsistency in the way anti-gambling campaigners

want internet gambling regulated. They want online games to emulate
casinos’ speed of play without casinos’ stake limits, and they want the
stake limits of gambling machines without the fast play of gambling
machines. It is a pick-and-mix approach in which the least appealing
elements of traditional gambling are applied to digital gambling. Naive
attempts to recreate bricks-and-mortar gambling in the online space would
truly lead to ‘an analogue law in a digital age’.

Deposit limits
An extreme variant of capping stakes is capping the player’s overall
spending. The Social Market Foundation has proposed a £100 per month
cap on deposits based on its estimate that households can afford to spend
£23 on gambling per week (Noyes and Shepherd 2020). This figure is
derived from the Joseph Rowntree Foundation’s Minimum Income Standard
which attempts to calculate the amount of money people need to attain
an ‘acceptable’ standard of living. This, in turn, is based on a shopping
list compiled by focus groups which goes far beyond the necessities and
invariably produces high figures (Snowdon 2014). The 2020 edition
concluded that a couple with two children needed to earn £37,400 per
annum to have an ‘acceptable’ lifestyle.

The Social Market Foundation defines a ‘low income’ as 75 per cent or

less of the Minimum Income Standard. It then calculates how much
households can afford to spend on ‘social and cultural activities’ - which
could include gambling - before they drop below this poverty line. For the
group with the lowest income (single pensioners) the figure is £45. The
authors then produce a different estimate of how much can be spent by
a person ‘beyond their and their family’s means without necessarily
amounting to severe hardship’. They do not explain what this means or
how it is calculated, but the figures range from £23 to £48 a week. The
authors opt for the lowest of these as the betting cap and round it up to
£100 a month.

The methodology is questionable and it seems inappropriate to set a cap

for everybody based on the supposed needs of those who have least to
spare. It is also extraordinarily paternalistic. The government says it
respects ‘the freedom of adults to choose how they spend their money’
(DCMS 2020a). This is a basic right in a free society. There is no other
market in which consumers are restrained by the state from spending
more than a certain amount of money. It is inconceivable that anyone
 28

would suggest rationing the amount people can spend on other ‘social
and cultural activities’, let alone at a level that is less than the price of
modest restaurant meal.

The Social Market Foundation describes its deposit limit as a ‘soft cap’
because people would be allowed to spend more than this - subject to
‘closer oversight’ - if they could prove they can afford it. They do not explain
how this would be done. Perhaps by contacting the players’ bank or by
demanding to see pay slips? It is hard to imagine any process that would
not require significant bureaucracy and invade privacy. Ordinary people
who want to gamble with their own money would be treated as if they were
taking out a mortgage or living off the proceeds of crime. It would be easier
for an individual to invest £50,000 on a risky stock market investment than
place a £200 bet on Liverpool winning the Premiership.

This is not to say that companies should never ask questions about whether
their customers are spending too much. One of the advantages of online
gambling is that it can keep track of how much individuals are spending
and track unusual patterns of play. Under the Social Responsibility Code
3.4.1 of the Licence Conditions and Codes of Practice, operators are required
to interact with customers to minimise gambling-related harm. The industry
is instructed to look out for a range of indicators, including length of session,
frequency, failed deposits, use of multiple payment methods, previous self-
exclusions, erratic betting patterns, chasing losses, and many more. They
are told to intervene when customers breach deposit or loss thresholds
which are set by the company and should be ‘based on the average available
income for your customers’ (Gambling Commission 2019: 6).

Operators can, and do, intervene by suspending customers’ accounts and

speaking to them directly. Personal contact with players is one of the
benefits of the much-maligned VIP schemes,7 but there is a limit to how
much any business can pry into its customers’ lives. There is a case for
making this requirement more specific, with a threshold set by the Gambling
Commission, but the onus should be on the industry and regulators to
safeguard high risk individuals, rather than requiring ordinary punters to
jump through hoops to spend their own money on a legal activity.8

7  The Gambling Commission (2019) understands this and tells operators: ‘Even if you think
the customer can afford it, they may still be experiencing gambling harms. Your enhanced
contact with your VIPs means you have many opportunities to get to know them well and
make better informed decisions’.
8 It also seems likely that a problem gambler will be more willing to jump through these
hoops than an ordinary punter who wants to place the occasional large bet.
 29

Other issues
Much of the recent debate has centred on the Gambling Commission,
which has been criticised for being too slow to act when companies break
the rules. Some have even called for the Commission to be replaced by
a new regulatory body. This paper takes no view on this except to note
the case for enforcing gambling laws strongly and consistently. Nor do we
take a view on how much the regulator’s budget should be (the Gambling
Commission is currently funded by industry licence fees which amounted
to £19 million in 2018/19).

It has been suggested that the gambling industry be required to pay a

levy to fund services for problem gamblers. The vast majority of operators
are already committed to donating at least 0.1 per cent of their Gross
Gambling Yield (revenue before expenses) towards ‘safer gambling’
projects and the five biggest firms have promised to increase this to one
per cent by 2023. Whether this is sufficient and whether these payments
should be mandatory are not questions that directly touch on economics
and so we leave them to one side.
 30

The risks of excessive regulation

The challenges of regulating the internet are well known. The UK government
can control how registered gambling companies operate, but they can do
little about the rest of the world. The challenge to regulators is to ensure
a sufficient degree of consumer protection without driving punters to the
unregulated sector.

Governments can compel internet service providers to block certain

websites, but it is an endless game of whack-a-mole and anyone with a
virtual private network (VPN) can get around such restrictions with ease.9
It is naive to hope that UK consumers can be prevented from accessing
high-stake casino content when people use the internet to buy hard drugs.

In Sweden, online gambling operators have been required to have a

licence and pay tax at 18 per cent since January 2019. Under this system,
which is not dissimilar to the UK’s, official estimates suggest that 85-87
per cent of online gambling takes place in the regulated sector.10 Research
by Copenhagen Economics found a slightly lower range of 81-85 per cent,
but this rose to over 95 per cent for horse racing, lotteries and bingo, while
falling to 72-78 per cent for online casinos (Lundvall et al. 2020).

Players of online casino games, slots, poker etc. therefore seem particularly
willing to use unregulated websites. These are the consumers who would
be most affected by the kind of policies currently being proposed in the UK.

9 Virtual private networks allow the user to pretend to be using the internet in another
country.
10  In the UK, profits from remote gaming made from customers based in the UK are taxed
at 21 per cent, regardless of where the company is based. This was increased from 15
per cent in April 2019.
 31

The authors of the Copenhagen Economics report conclude that the drivers
of unregulated online gambling are availability, ease of entry, attractiveness,
consumer willingness and the similarity between the unregulated websites
to their regulated rivals. Neil McArthur, the chair of the Gambling
Commission, has said that he ‘does not see a lot of evidence’ of ‘a
burgeoning black market’.11 This is a result of Britain’s relatively liberal
gambling laws, which have so far given consumers little reason to look
elsewhere. Nevertheless, recent research by PricewaterhouseCoopers
(2021) found that 4.5 per cent of UK online gamblers had used an unlicensed
operator in the past twelve months and 44 per cent were aware of at least
one unlicensed gambling website. This is not a bear that should be poked,
particularly since McArthur himself has acknowledged that unregulated
websites target problem gamblers who have self-excluded through the
GAMSTOP system and that ‘[c]riminals seeking to circumvent the regulated
sphere and exploit the vulnerable are demonstrating increasing
sophistication, complexity and capability which poses challenges to us to
keep pace’ (McArthur 2021: 3).

Protecting the vulnerable and preventing gambling becoming a source of

crime are two of the three key objectives of British gambling law. The
policies proposed by anti-gambling campaigners could undermine both
of these by stimulating demand for unregulated websites that can be easily
found via internet forums, search engines and affiliate sites. Many players
will be unwilling to tolerate online content that has been made deliberately
tedious and unexciting by limits on speed of play and stakes/prizes.
Unregulated online casinos closely resemble their regulated competitors
and, if advertising is also banned, consumers could have great difficulty
distinguishing one from another.

11 Public Accounts Committee, oral evidence, 27 April 2020 (https://committees.

parliament.uk/download/file/?url=/oralevidence/310/
documents/5421?convertiblefileformat=pdf&slug=oe00000310pdf).
32

Conclusion

There has been no shortage of regulation and self-regulation in the gambling

industry in recent years. None of it has satisfied anti-gambling campaigners,
but it is sufficient to fulfil the government’s longstanding objectives of
protecting children and vulnerable people, preventing gambling being a
source of crime, and ensuring that gambling is conducted in a fair and
open way. A sensible response to cases of misconduct is not to create
yet more rules but to enforce the rules that already exist.

Problem gambling is endemic at low levels in all societies, but in Britain

its prevalence is lower than average and has been unaffected by the
significant changes in the availability and promotion of gambling products
over the last twenty years. Yet the 0.6 per cent of adults who are classified
as problem gamblers have been used as weapons in a permanent war of
attrition against gambling. The hard truth is that nothing can stop a
pathological gambler from losing more money than they can afford if they
are so inclined. The government could accept this reality and implement
safeguards for problem gamblers while respecting the right of adult
consumers to spend their money as they choose. The consequence of
restricting consumer choice online will be a shift towards unregulated,
untaxed websites which have fewer safeguards.

Technology should be seen as the solution, not the problem. It is technology

that allows customers to self-exclude, set deposit limits, set playing times
and opt out of receiving inducements, such as free bets. The ability of ‘Big
Data’ to identify problem gamblers and prevent harm is unlike anything
we have seen before. In the past, gambling companies often had no idea
who their customers were. Today, the regulated online sector not only
knows their customer’s name and address (which they check with credit
agency databases), but how much they spend, what they play and how
they play. The company knows if they have self-excluded from any other
 33

regulated website. Algorithms are used to identify ‘markers of harm’, such

as chasing losses, switching between products and playing late at night.
These red flags trigger interventions. At the low end, they include e-mails
reminding the customer about deposit limits or being taken off mailing lists
offering bonuses and inducements. Those deemed to be at higher risk
will receive a phone call or be given a spending cap or have their account
suspended, sometimes permanently.

Not every company uses their technology to prevent harm in the same
way, but they could. Best practice could be made standard. There is
currently a mix of regulation, self-regulation, guidance and private initiatives
aimed at reducing gambling harm that could be consolidated, formalised
and made legally binding. Regulated online operators use a range of
practical harm reduction measures which advance the government’s
objectives without infringing the rights of the average punter or handing
a competitive advantage to the unregulated sector. It is these practical
solutions, not the blunt tools of anti-gambling activists, that should be the
focus of the government’s review.
34

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 38

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